MONTCLARE
CAPITAL PARTNERS
We help US and Canadian founders, groups and investors build the European side of their business through Dutch holding structures, with the substance and treaty position that cross-border flows require.
Structuring a Dutch BV as the European holding platform above US or Canadian operations, so that European revenue, subsidiaries and reinvestment sit in one vehicle rather than being handled transaction by transaction.
Aligning the double tax treaty position so that dividends, interest and royalties leaving Europe are not taxed twice, and documenting the substance behind the structure before any authority asks for it.
Placing and licensing intellectual property from the Netherlands where the business genuinely operates from there, with the transfer pricing documented rather than assumed.
Preparing the corporate structure so that it survives the due diligence of an institutional round or a trade sale, which is where improvised structures are usually discovered.
A technology group headquartered in Delaware was expanding its commercial operation into Europe. It faced heavy double taxation and had no efficient European gateway through which to repatriate dividends under the US tax framework.
Designed and structured a transatlantic gateway through a Dutch holding company, aligning the applicable double tax treaties and structuring the intellectual property so that withholding at source could be mitigated.
A clean European corporate structure through which transatlantic flows can be channelled with legal certainty, tax treatment aligned with international standards, and a base prepared for future institutional investment rounds.